A Critical look at the City of L.A.'s Water Supply Policy

Tag: Paper water

The City of Los Angeles water plans in the past have projected significant amounts of water that later never came. These large sums of water have been used to approve small and large projects going back to 1990.

When projects are reviewed by city planners, the figures cited in the city's water plans are supposed to assure the community that there is sufficient water for the project over the next 20 to 25 years after they are approved and that the project will not pose a burden to the city's water supply during that period.

Over a 24 year period, this missing water would be equivalent to 4.35 million acre feet which is slightly more than a full years worth of California Aqueduct water at full allocation.

Now that we find that the City of Los Angeles routinely props up its water portfolio using 'paper water' so where do we find it? We first find evidence of the city's reliance on paper water in the groundwater projections cited in each of the Urban Water Management Plans between 1985 and 2005.
Groundwater supply is just 67% of UWMP projections.
The chart at the right plots the gap between the actual groundwater supply the city had access to and the anticipated supplies that each UWMP projected. The gap between the two is the paper water that would be used to as evidence that medium and high density projects going through the planning process would have sufficient water when in fact they didn’t.
The city routinely projected supplies that ranged from 103,000 AF to 155,000 AF during that period. Including a brief period between 1997 and 2000 of exceptionally high pumping, the actual amount of well water produced by the city was 33% below expectations. Far below the city's expectations and glossy presentations that suggested that growing groundwater supply would help the city meet its needs and allow its growth ambitions.
Despite the city's average of just 71,000 AF since 2001, the city's current 2010 water plan continues propping up it's paper water inventory citing that it should an average of 107,426 af/y in available groundwater supplies between the years 2020 and 2035.
Between 2000 and 2014 the city's groundwater supply would remain flat at 71,059 af/y which is far below any of the past UWMP projections that ranged from 103,000 af/y to as high as 152,000 af/y.
Paper Water
This gap between 'projected or anticipated supply' and 'actual supply' is an unfortunate characteristic of the city's water supply. It's a promise spanning 5 water plans and 25 years that was used to mischaracterize the city's supply to approve high density development.
The City's failure to meet groundwater projections stems primarily from the fact that it is just storage. The City of Los Angeles Stormwater Program reports that the city captures just 27,000 AF of water to recharge the underground storage. The reason for this can be found in Upper Los Angeles River Area Watermaster reports which state that "The continued growth of residential, commercial, and industrial developments has required that more water be imported to supplement the local groundwater supplies in ULARA over time. Imported supplies to ULARA are from the Los Angeles Aqueduct and from MWD".
Because of the extent of development in the valley, much of today's potential groundwater supply is simply channeled into storm drains and down the LA River. Secondly, ULARA reports that many of the San Fernando Valleys groundwater pumps have been taken out of service due to groundwater contamination.

This graph shows the City of Los Angeles's history of 'paper water' since 1990 and the actual amount of water it has been able to obtain. Paper water is the gap between what the city anticipated it would need for it future growth versus the amount of water it actually received. The projections appear in the city's Urban Water Management Plan (UWMP) which is published and approved by the city council every five years.
The city uses paper water along with real water to demonstrate that it has sufficient water supplies for the thousands of medium and high density projects going through the planning process. As time goes by however the city has not been able to access that water which has created a severe deficit resulting in a drought. Despite not having access to this water, each new water plan continues to anticipate levels of water supplies that it clearly has no access to.
Residents caught in the middle of this vicious drought/growth cycle and have been forced pay for this policy with higher utility prices, enforcement actions, and lower property values.
Chart showing the gap between actual supply the city receives and anticipated supply projected in each UWMP.

Part IV in a series describing L.A.’s water supply problems, the drought and the policies that produced it.L.A.'s PAPER WATER
Urban Water Management Plans of 1990, 1995, 2000, & 2005 had all projected huge demand requirements and provided us with solutions on how it would met. However, as each superseding UWMP was approved, it left behind a growing legacy of plans with a history of projections that were never met. Over time, it became apparent that this is not simply a miscalculation but likely an intentional effort by the city to mislead the public using ‘paper water’.
Paper water is water that utilities claim they have access to, but is difficult or impossible to access for various reasons. You can't drink paper water or cook with it but you can make lots of promises with it.
The 2009 California Water Plan Update describes such a scenario in an article titled Water for Growth (E. Hanak/PPIC) stating that "A majority of utilities reported considerable normal-year surpluses, both now and 20 years hence, raising the possibility that many are banking on “paper water” for their margin of comfort."
Generally the City of Los Angeles hides its supply shortage behind promises of water that it could never actually deliver on such as groundwater, recycled water and LA Aqueduct water.
Large Projects
One very typical example where paper water was cited would be the massive Playa Vista development that was approved in the early 2000's. The project's water demand which was based on the 2000 UWMP stated:
"LADWP anticipates annual water demand within the Department’s service area to increase by 2010 to between 718,000 AF (in a normal year) and 761,000 AF (in a dry year), which represents a demand increase of 5.7 percent to 12.1 percent, respectively, between 2002 and 2010.Fig 1 - Projected Supply v. Actual SupplyThis increased demand in water use is accounted for in LADWP’s Final Year 2000 Urban Water Management Plan Update, and LADWP has identified various means and options for securing adequate water supplies to meet the needs anticipated for 2010, as well as through the year 2020. Ref: EIR No. ENV-2002-6129-EIR"
However the anticipated annual supply of 718,000 AF never materialized by 2010 nor did the 757,000 AF promised by 2015 as shown in Figure 1 at the right.
In 2010 the city water supply was 25% below the projection cited in the Playa Vista EIR at just 540,229 AF and it fell even further behind by 2015. The average yearly supply of 617,645 af/y between 2000 and 2014 was 23% below the projections 2015 projection. Neither aqueduct water, groundwater or recycled water projections were met.
The promise of up to 799,000 af/y of water cited in this EIR is what we would call ‘paper water’. It's this promise of water that contributed to the approval of the project but it was water that can never be had.
Fig 2 - The 2000 UWMP's Paper Water
This particular development is not an isolated situation. Literally every project in the city that has been approved since 1990 cites the inaccessible water in the city's UWMP. Prior and subsequent UWMP's also projected supply levels that could not be achieved. The 2005 water plan cited 705,000 AF this year and up to 776,000 AF by 2030. Even the current 2010 UWMP has similarly projected supplies in excess of 710,000 AF by 2035.
The City of Los Angeles has not been able to produce water supplies in excess of 690,000 AF since 1989.
Smaller Projects Benefit by Paper Water
Large projects with 500 units or more are required by SB-221 to obtain written verification that long term water supply is available for the project. This written verification goes into a tedious analysis of the projects demand and then always comes to the conclusion based on the UWMP's paper water that "adequate water supplies would be available to meet the estimated water demands of the proposed developments..."
The thousands of smaller projects with 499 units or less that are winding their way through the planning process are exempt from this formality. They need only cite the current UWMP which includes all existing and planned future uses of the city's water supply then come to the same conclusion that "that adequate water supplies would be available to meet the estimated water demands of the proposed developments..."
To date, literally every project approved since 1990, both small and large projects alike have been the beneficiary of paper water but it hasn't benefited residents.
Paper Water may be Political Cover
The city's most recent 2010 UWMP greatly lowered projections but that had not stopped or slowed down the approvals of large or small projects alike. The reason why could be found in a statement made by the DWP back in 1990 saying that approving projects is ultimately a "political decision to be decided by the Mayor and the City Council". So it's likely that the water departments insistence on such large water supply projections year after year is to provide political cover to for approving all of the developments making their way through the planning process.
In the 2009 California Water Update, the article Water For Growth alludes to that by noting "...even in jurisdictions with municipal water departments, elected officials may take a shorter-term view of resource adequacy than area residents do. If—as is often asserted—land-use authorities are aligned with predevelopment forces, they may be inclined to favor growth, even if it means higher costs (or a loss in property values) to the community down the road."